An Argument for Gay Marriage

Running head: ARGUMENT FOR GAY MARRIAGE

An Argument for Gay Marriage
Kristina Thielen
Friends University

Abstract
The premise of this paper is to prove that solid reasoning for denial of gay marriage is currently absent, and that legalization would provide much-needed equality to these unions. Arguments discussed include the "special rights" argument, the financial cost of legalizing same-sex marriage, the social belief that such marriages are "inherently wrong" or contradictory to America 's Judeo-Christian foundation, and the conviction that legalizing same-sex marriage would threaten the institution of marriage itself. The work concludes that that there is no demonstrable validity to the most commonly used arguments against gay marriage, and that denial of the right for homosexuals to marry constitutes discrimination.

An Argument for Gay Marriage
Civil marriage is at once a deeply personal commitment to another human being and a highly public celebration of the ideals of mutuality, companionship, intimacy, fidelity, and family. ‘It is an association that promotes a way of life, not causes; a harmony in living, not political faiths; a bilateral loyalty, not commercial or social projects. ' (Massachusetts Lawyers Weekly, 2003, para. 34)
If marriage is such a soulful, binding occurrence, why would American society choose to deny a segment of the population the right to experience it? That question is central to the debate of gay marriage. Some opponents use the argument that granting gays the right to marry is a "special right," or that the financial cost of gay marriage benefits to the United States government and to businesses is prohibitive. Others espouse the position that gay marriage is just inherently wrong. Still others argue that same-sex couples ' bid for legal marriage actually threatens the institution of marriage itself, and is contradictory to America 's Judeo-Christian roots. All of these arguments are based upon dubious evidence and personal fears. Absent solid reasoning for denial, gay marriage should be legalized to provide equality to these unions.
The "special right" argument consists of the erroneous belief that granting the minority a right that the majority already has access to is a "special right." The problem with this argument is that it assumes that the entire population starts out with equal rights, and it follows that any further rights granted to gays must then be "special" (Bidstrup, 2004, para. 30).
In 1996, Congress passed the Defense of Marriage Act (DOMA), which was signed into law by President Bill Clinton on September 21 of the same year. DOMA provides that each state may deny Constitutional marital rights to same sex couples who have been married in other states. It also defines marriage, for purposes of federal law, as "a legal union of one man and one woman as husband and wife" (as cited in Wikipedia, 2006a, para. 1). The Federal government recognized in a 1997 memorandum that there are approximately one thousand forty-nine federal laws in which marital status is a feature (United States Government Accounting Office [USGAO], 1997, p. 2). In a 2004 update to that memorandum, the USGAO identified eighty-nine additional laws involving marital status, for a grand total of one thousand one hundred thirty-eight "federal statutory provisions…in which marital status is a factor in determining or receiving benefits, rights, and privileges" (p. 1). Not to be forgotten are the approximately four hundred individual state 's rights awarded to married couples in the United States (Ontario Consultants on Religious Tolerance [OCRT], 2001, para 3).
Of those state and federal rights, three of the most important are decision-making powers in the event of medical emergency or death, civil rights and judicial protections, and the financial benefits of legally recognized relationships. As an example, the legal rights guaranteed to heterosexual married couples in medical emergencies or after a death are not guaranteed to homosexual partners (Kaye, 2006, para. 18). Anecdotal evidence abounds in the form of stories of estranged families who step in and take over medical decisions after an illness, injury or accident. While married couples enjoy guaranteed hospital visitation rights, homophobic medical personnel, uninformed hospital regulations, and hostile families can prevent homosexual partners from even visiting their loved one in the hospital (Bidstrup, 2004, para. 51). Often, these hostile families will totally ignore the surviving partner 's wishes regarding the treatment of the injured or deceased person, and in court have succeeded in negating powers of attorney previously executed. The website of The Ontario Consultants on Religious Tolerance (2001) explains that in the event of a death, a surviving homosexual partner can also be prevented from participating in the planning of the funeral, to the extent of being excluded from the ceremony itself. An estranged or hostile family may additionally take possession of previously shared property after a death, sometimes in direct defiance of legal documentation (para. 3). S. Bidstrup (2004), gay rights activist, notes, "There are hundreds of examples of this, even in many cases where the gay couple had been extremely careful to do everything right under current law, in a determined effort to protect their rights" (para. 52).
Not only does a legal marriage come into play during medical crises, it can affect basic civil rights and judicial protections. For instance, in federal assistance programs such as Food Stamps, Social Security Survivor 's Benefits, and Supplemental Security Income, benefit levels are dependent upon whether the applicant has an "eligible spouse" (USGAO, 1997, Enclosure 1, p. 1). What 's more, since homosexual couples cannot be "married," there are no laws protecting either partner in the event of dissolution of a relationship. The laws that married couples must comply with in these circumstances include community property laws, domestic violence protections, and child support enforcement (OCRT, 2001, para. 3). Under other denied judicial protections, homosexual partners can be compelled to testify against their partner in court, while married couples cannot. Although a partner 's testimony may help convict one of the pair, homosexual couples are not afforded the same rights to conjugal visits during imprisonment as are married couples (Bidstrup, 2004, para. 53).
Homosexual couples are also denied the financial benefits of legal marriage. For instance, both parties of a homosexual couple must pay the higher "single" income tax rates, and cannot share the tax break of a mortgage or child (USGAO, 1997, Enclosure 1, pp. 3-4). Gay couples are additionally denied the financial benefit of joint policies for home, auto, and health insurance (OCRT, 2001, para. 3). In fact, "Homosexuals contribute as much…to the funding of private and public family coverage, even when they have no access to it…" (Wikipedia, 2006b, para. 11). Lastly, because of the denial of legal recognition for same-sex marriage, homosexuals who have served in the military are unable to provide their partners with spousal rights to home loans, education payment assistance, and discounted medical care (OCRT, 2001, para. 3).
With all the talk about financial benefits, many might argue that the cost of providing benefits to same-sex married couples would be unaffordable to the government and to businesses. Studies and analyses conducted by the United States government, as well as privately funded organizations, should assuage that concern.
In a recent study utilizing data from Census 2000 and the National Compensation Survey, Badgett and Gates (n.d.) found the following:
Because same-sex couples make up such a small percentage of the U.S. population, the business benefits costs of allowing same-sex couples to marry will be no greater than the costs caused by fluctuations in the U.S. heterosexual marriage rates (para. 3).
Moreover, the U.S. Congressional Budget Office (2004) published an analysis that included the increase of expenditures and revenue resulting from the legalization of same-sex marriage. Their analysis estimated the net impact to the federal budget to be positive: it would improve the budget 's bottom line by almost $1 billion in each of the next 10 years (para. 5).
Despite the predicted positive financial impact to the nation 's budget, the discrepancies between the rights afforded to heterosexual married couples and the rights denied to homosexual couples speak to a glaring and grievous inequality in America 's treatment of her loyal citizens. Although many would argue that affording homosexuals the right to marry confers a "special right" to that population, that point of view fails to take into account that the rights being sought do no more than level the playing field. Equal rights are not "special rights."
Although the "special rights" argument is prevalent, the argument that "gay marriage is inherently wrong" is also quite popular. Arguments based upon this premise have much to do with misinterpretation of societal norms and/or Biblical verses, as well as personal fear; in reality, they have little to do with demonstrable validity.
Various gay marriage opponents utilize the "Polygamy, Incest, Bestiality" argument (PIB) regarding the "inherently wrong" nature of gay marriage. This is a form of the reductio ad absurdum fallacy, commonly referred to as the slippery slope argument. "Begin tinkering with the institution of marriage, they claim, and you start down a dangerous path with no reasonable stopping point" (Corvino, 2005, pp 501-503). J. Rauch, a Yale graduate and gay Jewish activist/journalist, writes:
The hidden assumption of the argument which brackets gay marriage with polygamous or incestuous marriage is that homosexuals want the right to marry anyone they fall for. But, of course, heterosexuals are currently denied that right. They cannot marry their immediate family or all their sex partners. What homosexuals are asking is for the right to marry, not anybody they love, but somebody they love, which is not at all the same thing. …A demand for polygamous or incestuous marriage is thus frivolous in a way that the demand for gay marriage is not. (as cited in Corvino, 2005, pp 507-508)
Another fallacious argument has to do with children. Many cite the social and accepted purpose of marriage to be procreation, thus immediately excluding homosexuals from marriage. This is a bifurcation fallacy, dividing a complex issue into an either/or argument. Strict adherence to this social policy would discourage not only homosexuals, but also post-menopausal women, men suffering from sexual dysfunctions, and those with genetic defects, among others, from enjoying the emotional and legal benefits of civil marriage (Wikipedia, 2006b, para. 22).What this fallacy fails to take into account is the fact that many heterosexual couples choose not to or are incapable of having biological children, and that many homosexual couples adopt children or take advantage of reproductive technologies. Writing for the majority, Massachusetts Chief Justice Marshall remarked in the decision Goodridge v. Dept of Public Health, (affording homosexuals the right to marriage in Massachusetts) "while it is certainly true that many…married couples have children together…it is the exclusive and permanent commitment of the marriage partners to one another, not the begetting of children, that is the sine qua non of marriage" (Massachusetts Lawyers Weekly, 2003, para. 50).
Upon realization of the fallacy of the previous claim, the argument segues to state that homosexuals should not have children anyway, as they are unfit to be parents. The common line of reasoning here is that "gay men and lesbians are mentally ill, that lesbians are less maternal than heterosexual women, and that lesbians ' and gay men 's relationships with sexual partners leave little time for ongoing parent-child interactions" (as cited in Patterson, 2006, para. 9). Also brought into question is the notion that children of gay and lesbian parents may have troubles with sexual identity, be more vulnerable to adjustment difficulties and behavior problems, and may experience difficulties in social relationships. In a review of studies dated 1978 to 2000, Anderssen, Amlie, and Ytteroy (2002) found that by measuring seven types of outcomes (including emotional functioning, sexual preference, stigmatization, gender role behavior, behavioral adjustment, gender identity, and cognitive functioning) in children of gay and lesbian parents, "children raised by lesbian mothers or gay fathers did not systematically differ from other children on any of the outcomes."(p.335). Although children of gay and lesbian couples may not differ from children of heterosexual couples, they do face social insecurities. An insightful comment was made by the Massachusetts Supreme Court:
Excluding same-sex couples from civil marriage will not make children of opposite-sex marriages more secure, but it does prevent children of same-sex couples from enjoying the immeasurable advantages that flow from the assurance of ‘a stable family structure in which children will be reared, educated and socialized. ' (Massachusetts Lawyers Weekly, 2003, para. 54)
In fact, the American Academy of Pediatrics (2002) released a policy statement that reads, in part, as follows:
Children who are born to or adopted by 1 [sic] member of a same-sex couple deserve the security of 2 [sic] legally recognized parents. Therefore, the American Academy of Pediatrics supports legislative and legal efforts to provide the possibility of adoption of the child by the second parent or coparent in these families. (p. 339).
What the American Academy of Pediatrics advocates is the raising of a child by two involved parents, regardless of sexual orientation. With the steady increase in single-parenting, divorce and out-of-wedlock births, many Americans have been scared into supporting conservative politicians who use the platform of "family values." It is not unusual for these politicians to use the argumentum ad populum fallacy, or fallacy of mob appeal, which best describes the politically polarizing argument that legalization of gay marriage would threaten the institution of marriage itself. The best rationale again comes from Massachusetts Chief Judge Marshall:
Recognizing the right of the individual to marry a person of the same sex will not diminish the validity or dignity of opposite-sex marriage, any more than recognizing the right of an individual to marry a person of a different race devalues the marriage of a person who marries someone of her own race. If anything, extending civil marriage to same-sex couples reinforces the importance of marriage to individuals and communities. That same-sex couples are willing to embrace marriage 's solemn obligations of exclusivity, mutual support, and commitment to one another is a testament to the enduring place of marriage in our laws and in the human spirit. (Massachusetts Lawyers Weekly, 2003, para. 60).
In contrast to the logic of secular argument, many challengers of legalization utilize America 's Judeo-Christian foundation by citing ambiguous Biblical quotes that allegedly proscribe homosexuality in its entirety. Reserving the argument regarding separation of church and state, ample evidence exists to refute the passages commonly cited.
Leviticus 18:22 is the most often quoted verse. It reads, "You shall not lie with a man as with a woman; it is abomination" (as cited in OCRT, 2004, para. 10). On the surface, this verse clearly states homosexuality to be against the word of God. But R. Carroll, pastor of the Family of Faith Church in Wichita, Kansas, has a different opinion: taken within the context of its book, the verse has a very distinctive meaning. Carroll clarifies that Leviticus 18:22 occurs within the context of the Holiness Code (personal communication, July 14, 2006). The Mormon organization Affirmation (2006) seeks to explain:
The purpose of this Code was to protect the Israelites from the idolatrous practices of the pagan [sic] who surrounded them…In this setting, it is more reasonable to infer that these verses are referring to the ritual homosexual prostitution associated with these pagan fertility cults. Thus, it is not homosexuality as such that is condemned but idolatrous sexual practices. (para. 9)
Affirmation (2006) also asks why "these passages are taken as binding today while other ‘moral ' condemnations found in the same chapters are not?" (para. 10) Eating shellfish is an abomination, per Leviticus 11:10. Verse 18:19 of Leviticus states that a man who has sex with his wife during her menstrual period should be banished. Leviticus 19:19 bans the wearing of garments made of more than one type of fiber, as well as the planting of more than one type of crop in the same field. Men with certain physical disabilities are prohibited from serving in the priesthood, according to Leviticus 21:16-21. (B. Mason, personal communication, July 14, 2006). "Those who argue that these scriptures condemn homosexuality…have the burden of explaining how they can absolutize [sic] one passage while freely ignoring another" (Affirmation, 2006, para. 10).
The other often-quoted-but-little-researched section of the Bible used to condemn homosexuality is the story of Sodom and Gomorrah. This passage is historically very germane to the subject of same-sex relations. The premise is that God hated the acts of homosexuals so much that "he planned to destroy them to keep their filthy lifestyle from spreading" (OCRT, 2006, para. 10). This story was so prevalent that the acts between homosexual men were labeled as "sodomy" and declared illegal under American law. The last of these sodomy laws was struck down by the United States Supreme Court in their 2003 decision Lawrence v. Texas (Kaye, 2003, para. 6). The back story of this section of the Bible is that these cities were populated by the Canaanites, who were known pagans and practiced "adult human sacrifice, cannibalism, and temple prostitution." Lot, Abraham 's nephew, lived in Sodom among the pagans. God sent two messengers, in the form of angels, to warn Lot that He was displeased with the residents of a certain geographic area. An angry mob formed, wanting Lot to hand his visitors over to them. It is not specified what the mob had planned, but the inference is that there was a distinct lack of hospitality (Lighthouse Ministries, 2002, para. 19-27). Recognizing menace, Lot offers his two virgin daughters in place of the visitors, an offer which is refused. The angels then blind some of the mob, and urge Lot and his family to leave immediately. God subsequently smites the whole area (OCRT, 2006, para. 7). The ambiguity of this story is obvious: was God mad about just the homosexuality of the citizens, or was He actually upset with the inhospitality the mob shows towards His messengers? Is this a cautionary tale against "sodomy," or a warning against the rejection of prophets? (Affirmation, 2006, para. 7) The Ontario Consultants on Religious Tolerance (2006) remark:
There is ironic aspect to this passage that is rarely discussed: To judge by other biblical references to Sodom, God seems to condemn the citizens for insensitive treatment and harassment of others. But this is the very passage that many…use to verbally attack gays and lesbians. (para. 49). With many raised in the traditional Judeo-Christian values, it is no surprise then, that the idea of homosexual marriage, indeed homosexuality itself, at times inspires fear. American society immerses itself in sex of all natures, and yet is curiously fighting against that immersion. "A society saturated with sex breeds its own reaction among those deathly afraid that temptation will sunder their world" (Moates, n.d., p. 191). While the concern of recruitment from the heterosexual community is alive, the greater fear is the fear of the unknown. D. Moates (n.d.), in the essay Fear Itself: Meditations on Gay Marriage explains:
In a pluralistic democracy, it is inevitable that we will hear from people with ideas that we don 't understand or accept. Fear is what magnifies these ideas into a threat…The gay rights movement, particularly the movement 's demand for marriage equality, inspires fear in part because the issues related to homosexuality are unfamiliar to many people… (pp. 193-195) Moates ' statement is supported by J. Lampman (2003), staff writer for The Christian Science Monitor: "Personal contact with homosexuals is [also] crucial in shaping views…Americans of all ages who have a friend, colleague, or family member who is gay or lesbian are roughly twice as likely to favor equal marriage rights" (para. 15). This dynamic is also noted by B. Mason*, who has been in a relationship with his partner, J. Mickey*, for 7 years. He tells the story of an older straight couple in their neighborhood who had originally come to know each of the gay couple individually. Not having the chance to "look through the filter of labels," the two couples became fast friends (personal communication, July 11, 2006). Societal "labels" and stereotypes concerning homosexual lifestyles do little to ease conservative fears, and in truth misrepresent the majority of the homosexual community. There seems to be a common assumption that gays and lesbians would not want marriage, as they are enveloped in a non-stop whirlwind of interpersonal instability and sexual promiscuousness. In reality, states S. Bidstrup (2004),
As gays age and mature, just like their straight cohorts, they begin to appreciate and find their way into long-term committed relationships. The values that such gay couples exhibit in their daily lives are often indistinguishable from those of their straight neighbors. They 're loyal to their mates, are monogamous, devoted partners. They value and participate in family life, are committed to making their neighborhoods and communities safer and better places to live, and honor and abide by the law…They take full advantage of their relationship to make not only their own lives better, but those of their neighbors as well. (para. 11-12)
L. Weil (1990), in the Anglican Theological Review, concurs by saying, "All men and women need the intimacy of companionship with others to be called out of the immaturity of the self-centered self" (para. 8).
This, again, is the heart of the matter. The fight for gay marriage rights is fundamentally about love. To prohibit gay marriage, especially with the current dearth of rational reasoning, is to refuse a social minority the opportunity for human fulfillment that comes from such love. "Without the right to marry…one is excluded from the full range of human experience and denied full protection of the laws for one 's ‘avowed commitment to an intimate and lasting human relationship '" (Massachusetts Lawyers Weekly, 2003, para. 40). Philosopher Immanuel Kant believed that a democratic society "needs to insist that rules work at least as well when applied to everybody as when applied to only a few" (as cited in Corvino, 2005, p. 527). In keeping with that idea, the Fourteenth Amendment of the United States Constitution guarantees that a state may not deny to any person within its jurisdiction the equal protection of the laws. Perhaps the most poignant statement we can apply to the current state of affairs comes from poet Langston Hughes:
I swear to the Lord
I still can 't see
Why democracy means
Everybody but me.

References
Affirmation. (2006). What do the scriptures really say about homosexuality? 16 paragraphs. Retrieved July 16, 2006, from http://www.affirmation.org/chapters/what_do_the_scriptures_really_say.shtml
American Academy of Pediatrics. (2002). Coparent or second-parent adoption by same-sex parents. Pediatrics, 109(2), 339-340.
Anderssen, N., Amlie, C., Ytteroy, E. (2002). Outcomes for children with lesbian or gay parents. Scandinavian Journal of Psychology, 43, 335-351.
Badgett, M.V., Gates, G. (n.d). The business cost impact of marriage for same-sex couples. 31 paragraphs. Retrieved July 17, 2006 from http://www.glad.org/marriage/busimpact.pdf
Bidstrup, S. (2004). Gay marriage: The arguments and the motives. 60 paragraphs. Retrieved June 8, 2007, from http://www.bidstrup.com/marriage.htm
Corvino, J. (2005). Homosexuality and the PIB argument. Ethics, 115, 501-534.
Kaye, C.J. (2006). Chief Judge Kaye dissenting opinion. In Hernandez v. Robles. 47 paragraphs. Retrieved July 17, 2006 from http://www.lambdalegal.org/binary-data/LAMBDA_PDF/pdf/694.pdf Lampman, J. (2003). Gay marriage: an issue that divides the faithful. The Christian Science Monitor, 24 paragraphs. Retrieved July 16, 2006 from http://www.csmonitor.com/2003/1121/p13s02-ussc.html
Lighthouse Ministries. (2002). Homosexuality and the scripture, 124 paragraphs. Retrieved July 16, 2006, from http://www.apostolicrestorationmission.4t.com/id27.htm
Massachusetts Lawyers Weekly. (2003). Goodridge, et al. v. Department of Public Health, et al., 165 paragraphs. Retrieved July 17, 2006 from http://www.masslaw.com/signup/opinion.cfm?page=ma/opin/sup/1017603.htm
Moats, D. (n.d.). Fear itself: meditations on gay marriage. The Virginia Quarterly Review, 186-195.
Ontario Consultants on Religious Tolerance. (2001). Legal and economic benefits of marriage. 6 paragraphs. Retrieved July 4, 2006 from http://www.religioustolerance.org/mar_bene.htm
Ontario Consultants on Religious Tolerance. (2004). Homosexuality in the Hebrew scriptures. 33 paragraphs. Retrieved July 16, 2006 from http://www.religioustolerance.org/hom_bibh.htm
Ontario Consultants on Religious Tolerance. (2006a). Homosexual passage in Genesis 19: the story of Sodom and Gomorra, 50 paragraphs. Retrieved July 16, 2006 from http://religioustolerance.org/hom_bibg.htm
Patterson, C. (2006). Lesbian and gay parenting. American Psychological Association. 45 paragraphs. Retrieved July 17, 2006 from http://www.apa.org/pi/parent.html
U.S. Congressional Budget Office. (2004). The potential budgetary impact of recognizing same-sex marriages. 38 paragraphs. Retrieved July 17, 2006 from http://www.glad.org/marriage/AR-M450_20040621_173537.pdf
U.S. Government Accounting Office. (1997). Defense of marriage act (GAO Document No. GAO/OGC-97-16). Washington, D.C.: Bedrick, B.
U.S. Government Accounting Office. (2004). Defense of marriage act: Update to prior report (GAO Document No. GAO-04-353R). Washington, D.C.: Shah, D.
Weil, L. (1990). The church does not make a marriage. Anglican Theological Review, 72(2), 11 paragraphs. Retrieved June 8, 2006 from EBSCO (Masterfile) database http://www.ebsco.com
Wikipedia. (2006a). Defense of marriage act. 22 paragraphs. Retrieved July 5, 2006 from http://en.wikipedia.org/w/index.php?title=Defense_of_Marriage_Act
Wikipedia. (2006b). Same-sex marriage. 38 paragraphs. Retrieved June 8, 2006 from http://en.wikipedia.org/w/index.php?title=Same-sex_marriage

References: Affirmation. (2006). What do the scriptures really say about homosexuality? 16 paragraphs. Retrieved July 16, 2006, from http://www.affirmation.org/chapters/what_do_the_scriptures_really_say.shtml American Academy of Pediatrics Anderssen, N., Amlie, C., Ytteroy, E. (2002). Outcomes for children with lesbian or gay parents. Scandinavian Journal of Psychology, 43, 335-351. Badgett, M.V., Gates, G. (n.d). The business cost impact of marriage for same-sex couples. 31 paragraphs. Retrieved July 17, 2006 from http://www.glad.org/marriage/busimpact.pdf Bidstrup, S Corvino, J. (2005). Homosexuality and the PIB argument. Ethics, 115, 501-534. Kaye, C.J. (2006). Chief Judge Kaye dissenting opinion. In Hernandez v. Robles. 47 paragraphs. Retrieved July 17, 2006 from http://www.lambdalegal.org/binary-data/LAMBDA_PDF/pdf/694.pdf Lampman, J. (2003). Gay marriage: an issue that divides the faithful. The Christian Science Monitor, 24 paragraphs. Retrieved July 16, 2006 from http://www.csmonitor.com/2003/1121/p13s02-ussc.html Lighthouse Ministries Massachusetts Lawyers Weekly. (2003). Goodridge, et al. v. Department of Public Health, et al., 165 paragraphs. Retrieved July 17, 2006 from http://www.masslaw.com/signup/opinion.cfm?page=ma/opin/sup/1017603.htm Moats, D Ontario Consultants on Religious Tolerance. (2001). Legal and economic benefits of marriage. 6 paragraphs. Retrieved July 4, 2006 from http://www.religioustolerance.org/mar_bene.htm Ontario Consultants on Religious Tolerance Ontario Consultants on Religious Tolerance. (2006a). Homosexual passage in Genesis 19: the story of Sodom and Gomorra, 50 paragraphs. Retrieved July 16, 2006 from http://religioustolerance.org/hom_bibg.htm Patterson, C U.S. Congressional Budget Office. (2004). The potential budgetary impact of recognizing same-sex marriages. 38 paragraphs. Retrieved July 17, 2006 from http://www.glad.org/marriage/AR-M450_20040621_173537.pdf U.S U.S. Government Accounting Office. (2004). Defense of marriage act: Update to prior report (GAO Document No. GAO-04-353R). Washington, D.C.: Shah, D. Weil, L. (1990). The church does not make a marriage. Anglican Theological Review, 72(2), 11 paragraphs. Retrieved June 8, 2006 from EBSCO (Masterfile) database http://www.ebsco.com Wikipedia Wikipedia. (2006b). Same-sex marriage. 38 paragraphs. Retrieved June 8, 2006 from http://en.wikipedia.org/w/index.php?title=Same-sex_marriage